Rigterink v. State
66 So. 3d 866
Fla.2011Background
- Rigterink convicted of two counts of first-degree murder and sentenced to death.
- Question presented centers on suppression of statements obtained after Miranda warnings; defendant argues warnings were deficient.
- Florida Supreme Court on remand from U.S. Supreme Court after Powell II reconsidered prior ruling in Rigterink I.
- Powell II held Miranda warnings must convey right to counsel both before and during interrogation; Powell I was overruled.
- Court ultimately holds the Miranda warnings given to Rigterink were sufficient under Miranda and Powell II, affirming convictions and death sentences.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the Miranda warning sufficient to convey right to counsel during interrogation? | Rigterink argues warnings were deficient. | State argues warnings satisfied Miranda and Powell II. | Yes; warnings sufficient under Miranda and Powell II. |
| Was the denial of testimony about Mullins' reputation error? | Rigterink contends excluded testimony prejudiced defense. | State asserts exclusion proper under Florida rules. | No abuse; exclusion proper. |
| Is Florida's capital-sentencing scheme constitutional under Ring and related authorities? | Rigterink challenges jury role/unanimity and Ring compliance. | State has consistently upheld the scheme. | No reversible error; sentences proportionate and properly imposed. |
| Is the lethal-injection claim ripe and/or meritorious on direct appeal? | Rigterink argues lethal injection violates Eighth Amendment/Article I, §17. | Not preserved; lacking new evidence; substantial precedent upholds procedure. | Not ripe; even if reviewed, claim lacks merit. |
Key Cases Cited
- Powell v. Florida (Powell II), 130 S. Ct. 1195 (2010) (clarified requirement to inform right to counsel during interrogation)
- Powell v. Florida (Powell I), 998 So.2d 531 (Fla. 2008) (held warning deficient for not conveying counsel during questioning)
- Florida v. Powell, 130 S. Ct. 1195 (2010) (see Powell II; federal standard applied)
- Traylor v. State, 596 So.2d 957 (Fla. 1992) (Florida Constitution independent protection; pre-interrogation warnings)